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… And I’m Here to Help

Certification Corner: what to do when the FCC knocks?

What’s the Ratio, Kenneth?Question posed in the Oct. 13 issue
(Exam level: CBRE)

It’s a little after 8 p.m. and your five-station cluster has settled into night automation operation. As usual, you are the last in the building. But now there are two people at the front door, holding up federal FCC IDs to the security camera. They request to inspect your station(s). Are they entitled to inspect at this late hour?

a. No, it’s a constitutional right to have an attorney present when questioned. They can come back when your attorney is present.
b. No, it’s after business hours, and meaningful management presence is absent
c. No, you’re off the clock
d. No, tours are only given by appointment
e. Yes
SBE certification is the emblem of professionalism in broadcast engineering. To help you get in the exam-taking frame of mind, Radio World Engineering Extra poses a typical question in most issues. Although similar in style and content to exam questions, these are not from past exams nor will they be on future exams in this exact form.

The simple rule of thumb: If you are radiating, you are subject to inspection. The answer to today’s question is the last one, “e.”

The Enforcement Bureau, the part of the FCC that inspects or orders up an inspection, wants absolutely no confusion on this issue and has published on its website answers to just about any inspection scenario questions you might ask. See

You can quote those pages to management or ownership if someone tells you that FCC inspection access is optional. In truth, as with the Borg, resistance is futile.

A paragraph from the FCC site succinctly sums up the issue:

Q: What happens if I do not allow the FCC agent to inspect my equipment?
A: Failure to allow inspection forecloses the opportunity to resolve the problem. Thus, refusal to allow inspection is a serious challenge to the commission’s authority to inspect radio stations and is a violation of the rules. Such a refusal may lead to revocation of a license, maximum monetary forfeiture or other commission sanctions.

FCC staffers, unlike those of the IRS in my experience, usually are courteous and justifiably proud of the team they’re on and the mission they fulfill. They will show you all the FCC ID you want.

If something makes you suspect a prank (say, the inspector looks about 19 and is wearing a halter top), call the FCC “emergency desk” at (202) 418-1122. Within minutes you’ll know whether she is bogus or a real (if youthful) inspector who simply may have failed to read the book “Fashion in the Workplace.”

Many FCC officials have worked in their assigned regions for years. If you have not had the pleasure of meeting them you should know them by reputation. So if inspector Lamont Cranston, a legend in your FCC district, shows up at your door with picture ID and his sidekick, don’t be a smarty and act stupid.

FCC employees are people too; they may have come far to visit you. So be a good host and let them know where the washroom is. If you have refreshments on hand, offer them. You want these official visitors to see you as professional and open. Be respectful, factual, accurate and, above all else, truthful.

Keep records close at hand. Public copies can be conformed but the originals of documents should be in the station offices. (A “conformed” copy is a duplicate of a document on which the signatures are printed or typed, rather than signed by hand.) Most of my clients store originals of critical documents, such as the main license, in a locked cabinet or safe in the GM’s office.

When it comes to paperwork, leave no doubt.
On conformed copies that are kept in the public file, note on the front page the total pages, the initials of who copied it and the date copied. Multipage document copies should always be stapled together.

If documents are in binders, provide an index on the front and put the documents inside in clear sheet carriers with a label for what is inside the carrier.

There are a few brilliant, inspired and talented FCC attorneys out there. The best advice I ever got from them about documents was to organize and identify your paperwork such that if all of it ever fell in a mess of a heap on the floor, every page could be identified on its own and put back into its proper place in moments. Such precise organization should be your goal.

A Notice of Apparent Liability is not something you want to receive. The goal is to avoid it through effective and complete compliance. An NOAL that sticks could open you to a license challenge. It usually involves a monetary fine and may be a drain on your time and legal budgets. Finally, it can brand you or your employer as unprofessional and sloppy.

(A postscript: Lamont Cranston was the name of “The Shadow.” Who knows what evil lies in the hearts of men? Like many of the inspectors I’ve encountered, he knew your violations even before he arrived. One of the great radio detectives, the Shadow confounded offenders in more than 900 episodes. Orson Welles amongst other great talents voiced the character.

Do you know the title of the only movie in which an FCC inspector was the hero? He actually got the girl in the end. It was “Phantom from Space,” produced in 1953. The FCC was disguised as the CAA, the Communication Authority. Handsome “B” actor Ted Cooper played the CAA inspector.

None of the above trivia will ever be on an SBE exam.)

The deadline for signing up for the next cycle of SBE certification exams is March 25 for exams given at the NAB Show in April.

Missed some Certification Corners or want to review them for your next exam? Find past Certification Corner articles under the Columns tab at

It’s Not the Flux Capacitor, MartiQuestion for next time
(Exam level: CBRE)

Your remote crew tells you that there is something wrong with their 10 watt 160 MHz RPU transmitter. On site you realize that you need to substitute a dummy load to ascertain if the problem is the transmitter or antenna. Your dummy is back on the bench but in your kit you have the resistors listed below. How can you quickly arrange them to make a workable 50 ohm load?

Quan Value (ohms) Power handling (watts) 4 100k 1/2 2 620 1/2 2 150 1/2 4 100 1 1 100 5
a. There is no solution as the 1/2 watts will blow no matter what at 10 watts input.
b. Put all the above resistors in parallel.
c. Put the four 100 ohm 1 watts in parallel and then series these with the 100 ohm 5 watt.
d. Make a series parallel network out of the four 100 ohm 1 watts (two series 100 ohms with these series pairs in parallel) and this network paralleled with the 100 ohm 5 watt.
e. Parallel all the 100 ohm resistors.